IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

GRACE LAWRENCE

Plaintiff,

v.

TRANS UNION LLC

CITY OF PHILADELPHIA

Defendant.

C.A. NO: 02-CV-4440

JOINT MOTION FOR EXTENSION OF TIME

Trans Union LLC (“Trans Union”) and Plaintiff (collectively referred to as the “Parties”),

by and through their undersigned attorneys, jointly move that the case be removed from the July 14

trial pool and rescheduled on or after August 25, 2003:

1. Plaintiff commenced this action alleging that Defendant Trans Union violated the Fair

Credit Reporting Act, 15 U.S.C. §1681 et seq. (the “FCRA”) because it reported certain allegedly

inaccurate credit information relating to Plaintiff. 

2. The Parties have engaged in serious settlement discussions and extensive discovery,

including written discovery and depositions of plaintiff, two Trans Union witnesses, and a third

party damages witness. The Parties have subpoenaed a third party vendor, but scheduling issues

have prevented that deposition from being conducted. A former Trans Union employee will be

deposed, if located. After such discovery has been accomplished, the Parties will resume settlement

discussions. If deemed appropriate, the Parties may seek a settlement conference with the Court

pursuant to the scheduling Order.

3. Counsel for Plaintiff and Counsel for Trans Union also have vacation plans which

will conflict with the July 14 trial pool schedule. Counsel for Trans Union, Bruce S. Luckman,

Esquire, has prepaid vacation plans (a non-refundable beach rental house) from July 18 through

Case 2:02-cv-04440-AB Document 16 Filed 06/10/2003 Page 1 of 2
August 3, 2003. Counsel for plaintiff, John Soumilas, Esquire also has vacation plans from August

2 through August 12, 2003.

4. Further, counsel for plaintiff and Trans Union are litigating several other FCRA

matters, including Sheffer v. Sears, Trans Union LLC, et al, 02-CV-1243 ((Schiller, J), which is

set for jury trial on August 18, 2003). Counsel for Trans Union is also previously set for jury trial

on August 20, 2003 in Northam v. Trans Union, 3:03-CV-0143, United States District Court for the

Eastern District of Virginia (Hudson, J)

5. Accordingly, the Parties respectfully request that the Scheduling Order be modified

and extended as follows:

a) Trial pool, on or after August 25, 2003;

 6. This extension of time is sought in the interests of justice and is made in good faith

and not to unnecessarily delay the trial of this action.

WHEREFORE, Defendant Trans Union LLC and Plaintiff, Grace Lawrence, jointly,

respectfully request that this Court grant an extension of time.

Respectfully Submitted this 10th Day of June, 2003.

________________________________

JAMES FRANCIS

JOHN SOUMILAS

FRANCIS & MAILMAN, P.C. 

Land Title Building, 19th Floor

Philadelphia, PA 19110

(215) 735-8600; Fax: (215) 940-8000

Counsel for Plaintiff

________________________________

MARK E. KOGAN

BRUCE S. LUCKMAN

TIMOTHY P. CREECH

SATZBERG, TRICHON,

 KOGAN & WERTHEIMER, P.C.

1818 Market St., 30th Floor

Philadelphia, PA 19103

(215) 575-7600; Fax: (215) 575-7688

Counsel for Defendant,

Trans Union LLC

Case 2:02-cv-04440-AB Document 16 Filed 06/10/2003 Page 2 of 2